“TNMM”

Transfer PricingSection 92CSection 92C2,208 judgments

The decision most relied on for TNMM is Rampgreen Solutions Pvt. Ltd. v. CIT (377 ITR 533), cited in 196 judgments on BharatTax.

Leading authorities on TNMM

Rampgreen Solutions Pvt. Ltd. v. CIT

377 ITR 533 · 2015 · High Court

196

citing judgments

Knowledge Process Outsourcing (KPO) service providers are functionally dissimilar to Business Process Outsourcing (BPO) or Information Technology Enabled Services (ITeS) providers and cannot be compared for transfer pricing purposes, even under the Transactional Net Margin Method (TNMM). Further, companies with significantly different business models, such as those with extensive subcontracting, should be excluded as comparables.

Bausch & Lomb Eye Care (India) Pvt. Ltd. v. Additional CIT

381 ITR 227 · 2016 · High Court

127

citing judgments

The existence of an international transaction must be established before its arm's length price can be determined. An alleged 'excessive' AMP expenditure cannot unilaterally expand the scope of an international transaction if its existence is contested.

SAP Labs India Pvt. Ltd. v. ACIT

44 SOT 156 · 2011 · ITAT

100

citing judgments

Foreign exchange fluctuation gains or losses are operational in nature and must be included in the computation of the operating margin for both the assessee and comparable companies when determining the Arm's Length Price.

DIT (IT) v. Morgan Stanley & Co Inc.

162 Taxmann 165 · 2007 · Supreme Court

citing judgments

The profits of a Permanent Establishment (PE) must be determined on the basis of what an independent enterprise would derive, using the Transactional Net Margin Method (TNMM) for profit attribution. When applying TNMM, the operating profit from an international transaction should be compared with the operating profit margin of comparables.

Ranbaxy Laboratories Ltd. v. ACIT

68 Taxmann.com 322 · 2016 · High Court

citing judgments

When benchmarking export transactions, the Associated Enterprise (AE) can be considered the tested party if it possesses the least complex functional analysis. The Assessing Officer's acceptance of a methodology in prior years can also support its use.

Trilogy E-Business Software India (P.) Ltd. v. Dy. CIT

29 Taxmann.com 310 · 2013 · ITAT

citing judgments

For Transfer Pricing, this case clarifies that foreign exchange gains can be considered operating revenue for ITES providers, acknowledges the impact of offshore versus onsite development pricing on margins even when using TNMM, and affirms the use of a turnover filter for selecting comparable companies.

Capital IQ Information Systems India Pvt. Ltd. v. DCIT

32 Taxmann.com 21 · 2013 · ITAT

citing judgments

A change in depreciation policy impacts an entity's profitability, which is a key factor in assessing its suitability as a comparable company for transfer pricing analysis.

Electronic for Imaging (I) Pvt. Ltd. v. DCIT

85 Taxmann.com 124 · 2017 · ITAT

citing judgments

Comparability of a company for transfer pricing purposes must be decided afresh by the TPO after considering the facts recorded in prior tribunal decisions. The tribunal may direct exclusion of comparable companies based on such prior decisions.

Judgments citing TNMM

DCIT, New Delhi vs. M/S. Gujrat Guardian Ltd., New Delhi

ITA 157/DEL/2010[2003-04]Status: DisposedITAT Delhi16 Jul 2025AY 2003-04

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R

Section 92C

including export of float glass to its associated enterprise. In the Transfer Pricing Documentation, the international transactions were benchmarked using Transactional Net Margin Method (“TNMM”) method. By considering this method as Most appropriate method, the assessee has shown operating profit ratio of GGL at 27.26%, which as per assessee ... determined the arm's length price of international transactions of export of float glass, applying CUP method as against the TNMM applied by the assessee, holding that in the case of the assessee, same products have been sold to unrelated parties, and hence internal CUP would be the most suitable

DCIT, New Delhi vs. M/S Gujrat Guardian Ltd., New Delhi

ITA 4859/DEL/2009[2002-03]Status: DisposedITAT Delhi16 Jul 2025AY 2002-03

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R

Section 92C

Suntec Business Solutions Private Limited, Chennai vs. Deputy Commissioner of Income Tax, Corporate Circle 3(1), Chennai

In the result, the appeal filed by the assessee is partly-allowed

ITA 3252/CHNY/2024[2021-22]Status: DisposedITAT Chennai15 Jul 2025AY 2021-22

Bench: Shri George George Kand Shri S.R. Raghunatha

For Appellant: Shri Sharath Rao, Advocate &For Respondent: Shri AR.V Sreenivasan, CIT

Section 143(1)Section 143(2)Section 143(3)Section 143C(1)Section 144C(5)Section 92C

services to AE and operating margin of SWD segment have been accepted at arm’s length (which includes the salary cross charge) under TNMM :- 5 -: method. Therefore, the TPO is not justified in separately culling out the salary cross charge and making a separate TP adjustment. In this regard ... part of the operating cost base of the SWD segment which has been benchmarked to be at Arm's Length by application of the TNMM method (refer page 265 of PB, the TP Study), which has also been accepted by the TPO. After having accepted the net margin

Shree Dadar Digamer Jain Mumuksho Mandal, Mumbai vs. CIT(Exemption) Ward 2(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2446/MUM/2025[2023-24]Status: DisposedITAT Mumbai15 Jul 2025AY 2023-24

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2023-24 Shri Dadar Digamber Jain The Cit (Exemption), Mumukshu Mandal, Ward-2(3), 271/293, 271/293, Vs. Mumbai. N.C. Kelkar Road, Opp: Shivaji Park, P.O. Dadar (West) Mumbai-400028. Pan : Aacts8044A (Appellant) (Respondent) For Assessee : Shri A.N. Shah For Revenue : Shri Annavaram Kosuri Date Of Hearing : 11-06-2025 Date Of Pronouncement : 15-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld.Addl/Jcit(A)-2, Delhi [„Ld.Cit(A)‟], Dated 05-03-2025, Pertaining To Assessment Year (Ay) 2023-24, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

For Appellant: Shri A.N. ShahFor Respondent: Shri Annavaram Kosuri

Section 11(2)Section 11(3)Section 11(3)(c)Section 143(1)

Order pronounced in the open court on 15-07-2025 [ANIKESH BANERJEE] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 15-07-2025 TNMM 24 Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

Karl Storz Endoscopy India Pvt. Ltd., New Delhi vs. ITO, New Delhi

In the result the appeal of the assessee is allowed for the statistical purposes

ITA 4063/DEL/2016[2008-09]Status: DisposedITAT Delhi10 Jul 2025AY 2008-09

Bench: Shri Ramit Kochar & Shri Sudhir Kumarassessment Year: 2008-09 M/S Karl Storz Endoscopy Vs. The Income Tax Officer Ward-5(2) India Pvt. Ltd. D-181, New Delhi Okhla Industrial Area , Phase-1 New Delhi- 110020 Pan :Aaack4816D (Appellant) (Respondent)

Section 143(1)Section 143(2)Section 143(3)Section 92C(2)

invoked the provisions of the section 92C(3) (c ) of the Act. The Ld. TPO then proceeded with a fresh search by applying the TNMM method for bench marking in respect of the transactions of receipts of commission for marketing support services by treating the company as commission Agents

Deputy Commissioner of Income-Tax, Circle - 1(1), Pune vs. M/S. IAC International Automotive India Pvt.Ltd, Pune

In the result, the appeal of the Revenue is dismissed

ITA 749/PUN/2022[2013-14]Status: DisposedITAT Pune08 Jul 2025AY 2013-14

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

For Appellant: Shri Darpan KirpalaniFor Respondent: Shri Madhukar Anand

Section 143(2)Section 92Section 92C

Nature of International Amount (in INR) Most Appropriate No. Transaction Method 1. Rendering of offshore 134,764,629 Transactional Net engineering services Margin Method („TNMM‟) 2. Management fee payable 33,221,272 TNMM (Availing Business Support Services) 3. Interest paid on ECB 7,067,816 Other Method 4. ECB loan ... allocable cost along with a 5% markup. Accordingly, the assessee paid management fee of Rs. 33,221,272 to (“IAC Shanghai”). The assessee selected TNMM for benchmarking the said international transactions of management fee with IAC Shanghai which was not acceptable to the Ld. TPO. The Ld. TPO therefore issued

Addl. CIT, Special Range- 6, New Delhi vs. Nec Technologies India Pvt. Ltd., New Delhi

ITA 7392/DEL/2017[2010-11]Status: DisposedITAT Delhi04 Jul 2025AY 2010-11

Bench: Shri Ramit Kochar & Shri Sudhir Pareek

For Appellant: Sh. S.K. Jadhav, CIT DR

Section 143Section 144CSection 144C(5)Section 40Section 9(1)(vii)

Dispute Resolution Panel-II is legally justified in holding that strict functional comparability is required by ignoring the OECD guidelines that for TNMM relaxed comparability is required? 4. That the appellant craves leave to add, alter, amend or forgo any ground/(s) of appeal either before or at the time

Ssnc Fintech Services India Private Limited, Hyderabad vs. DCIT., Circle 8(1), Hyderabad

In the result, appeal of the Assessee is partly

ITA 916/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad03 Jul 2025

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, Ketan K. VedFor Respondent: Shri B. Bala Krishna, CIT-DR

Section 143(3)Section 144C(5)Section 920

into by it with it’s AEs. The appellant-company has carried-out TP analysis documents by adopting Transactional Net Margin Method [in short “TNMM”] as Most Appropriate Method [in short “MAM”]. The appellant-company has computed Profit Level Indicator [in short “PLI”] considering Operating Profit/Operating Cost [in short OP/OC ... other hand, supporting the order of the DRP submitted that, Infosys Limited passed all filters applied by the TPO. Further, when TNMM is selected for benchmarking analysis, it has resistance to minor differences and further, when we consider 35 percentile and 65" percentile, it takes care of 12 ITA.No.916/Hyd

Shaukat Ali Vali Mohammed Khan, Mumbai vs. ITO, Ward 31(2)(1), Kautilya Bhavan, Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 3324/MUM/2025[2011-12]Status: DisposedITAT Mumbai03 Jul 2025AY 2011-12

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2011-12 Shaukat Ali Vali Mohammed Ito, Ward-31(2)(1), Khan, Kautilya Bhavan, C-802, Pearl Horizon, Vs. Mumbai-400051. Bldg. No.3, Bandivali Hill Road, Jogeshwari (W), Mumbai-400102. Pan : Aiepk8948B (Appellant) (Respondent) For Assessee : Shri Ashish Verma For Revenue : Ms. Kavita P. Kaushik, Sr.Dr (Virtually Appeared) Date Of Hearing : 02-07-2025 Date Of Pronouncement : 03-07-2025 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Shri Ashish VermaFor Respondent: Ms. Kavita P. Kaushik, Sr.DR

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 36(1)(vii)

pronounced in the open court on 03-07-2025 [MS. KAVITHA RAJAGOPAL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 03-07-2025 TNMM 4 Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

Aristocrat Technologies India Private Limited, Noida vs. DCIT, Circle-5(1)(1), Noida

In the result, appeal of the assessee is partly allowed in the terms aforesaid

ITA 3091/DEL/2024[2020-21]Status: DisposedITAT Delhi03 Jul 2025AY 2020-21

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.3091/िद"ी/2024(िन.व. 2020-21) Aristocrat Technologies India P. Ltd., 8Tgh To 10Th Floor, Tower-11A, Plot No. 20 & 21, Candor Techspace, It/Ites Sez Complex, Sector-135, Noida, Up 201304 ...... अपीलाथ"/Appellant Pan: Aahca-9200-G बनाम Vs. Deputy Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle-5(1)(1), Noida, Up Assessee By : Shri Atul Jain, Chartered Accountant Ms. Nishi Bhutani & Ms.Preeti Agnihotri, Chartered Accountants Department By : S/Shri S.K. Jhadav, Cit(Dr) & Rajesh Kumar Dhaneshta, Sr.Dr सुनवाई क" ितिथ/ Date Of Hearing : 04/04/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 03/07/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 27.05.2024 Passed U/S. 143(3) R.W.S. 144C(13) R.W.S 144B Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’). 2. The Facts Of The Case In Brief As Emanating From Records Are: The Assessee Is Engaged In Providing Design & Development Services To Its Associated Enterprises (Ae’S). The Assessee Is Also Rendering Global It Services To Its Ae’S

For Appellant: Shri Atul Jain, Chartered AccountantFor Respondent: S/Shri S.K. Jhadav, CIT(DR) & Rajesh Kumar Dhaneshta, Sr.DR

Section 143(3)Section 234BSection 270A

instant appeal the assessee has assailed adjustment made in respect of provision of software and other services. The assessee applied Transactional Net Margin Method (TNMM) to benchmark international transaction. The method applied by the assessee was accepted by the Transfer Pricing Officer (TPO). The margins of the assessee i.e. OP/OC ... appeal are ground no. 4, 5 and 7 to 10. 3.1. The ld. Counsel for the assessee submits that the TPO has accepted TNMM as most appropriate method for benchmarking the transaction and has also not raised any dispute with regard to margins i.e. OP/OC reported by the assessee

Assistant Commissioner of Income Tax, Vapi Circle, Vapi vs. Wheel Flexible Packaging, Dadra

In the result, Revenue’s appeal is dismissed

ITA 1063/SRT/2024[2016-17]Status: DisposedITAT Surat30 Jun 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1063/Srt/2024 Assessment Year: (2016-17) (Hybrid Hearing) Assistant Commissioner Of Wheel Flexible Packaging, Income-Tax, Vapi Circle, C-24/25, Zero Tax Industrial Estate, Fortune Square Ii, 7Th Vs. Dadra, Dadra & Nagar Haveli –396230 Floor, Daman Road, Chala, Vapi-396 191 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaafw 2971 Q (Appellant) (Respondent)

Section 143(3)Section 250Section 92B

alternatively the Learned Commissioner of Income-tax (Appeals) ought to have considered selection of the comparable and working of ALP as per TNMM by the appellant-firm as correct and ought to have deleted the upward adjustment made by the learned Transfer Pricing Officer in this regard. 6. The respondent

Vaibhav Global Limited, Jaipur vs. DCIT, CC-4, Jaipur

ITA 1485/JPR/2024[2021-22]Status: DisposedITAT Jaipur30 Jun 2025AY 2021-22

For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR

Section 115JSection 115QSection 143(3)Section 144C(5)Section 36(1)(va)

case and in law, the Id. TPO, Ld. AO and the Hon'ble DRP erred in rejecting the Transactional Net Margin Method (TNMM) considered by the appellant as the Most Appropriate Method ('MAM') with Operating profit margin/ Operating Expenses ('OP/OE) as the Profit Level Indicator (PLI), without giving any cogent ... erred in applying 'Berry ratio' with Operating Profit/Value Added Expenses (OP/VAB) as the PLI under The Transactional Net Margin Method (TNMM) based on conjectures and surmises, without appreciating that the appellant is engaged in manufacturing activities and therefore, purchases and cost of production ought to be included in the cost

Vaibhav Global Limited, Jaipur vs. DCIT, CC-4, Jaipur

In the result, the appeal of the assessee in ITA no

ITA 1144/JPR/2024[2020-21]Status: DisposedITAT Jaipur30 Jun 2025AY 2020-21

For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR

Section 115JSection 115QSection 143(3)Section 144C(5)Section 36(1)(va)

Mirza International Limited, Kanpur vs. DCIT Circle 2(1)(1), Kanpur

The appeals of the assessee stand partly allowed

ITA 35/LKW/2022[2017-2018]Status: DisposedITAT Lucknow30 Jun 2025AY 2017-2018

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Shri Akshay Gupta, C.AFor Respondent: Shri Sunil Kumar Rajwanshi, D.R

Section 143(3)Section 40A(7)Section 80Section 92Section 92C

Domestic Transactions (SDTs) entered into between the eligible and non- eligible units of the assessee. The assessee had adopted Internal Transaction Net Margin Method (TNMM) as the Most Appropriate Method (MAM). The assessee was asked to show cause as to why transfer pricing adjustment should not be made ... /LKW/2022 Page 3 of 25 Margin/Operating Cost (OP/OC). The assessee furnished before the TPO a detailed explanation justifying the adoption of the internal TNMM as the Most Appropriate Method. However, the TPO was not satisfied with the explanation submitted by the assessee and he proposed an adjustment of Rs.3

Invesco(India) Private Limited, Hyderabad vs. DCIT, Circle -2 (1), Hyderabad

In the result, appeal of the Assessee is partly allowed for statistical purposes

ITA 111/HYD/2022[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Sriram SeshadriFor Respondent: Shri B Bala Krishna, CIT-DR

Section 143(3)Section 144C(5)

TPO/Ld. AO erred in not appreciating the fact that receivables are not a separate international transaction and under the Transaction Net Margin method (TNMM) for determination of ALP of the services, the impact of outstanding, receivables on the working capital adjustments is already taken into account and that there

Steven Angelo Pinto, Mumbai vs. ITO Int Tax 3(3)(2), Mumbai

In the result, the addition so made is directed to be deleted

ITA 922/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2022-23 Steven Angelo Pinto, Income Tax Officer, A-11, Tahnee Heights, (International Taxation)-3(3)(2) Nepean Sea Road, Vs. Kautilya Bhavan, Mumbai-400006. Bandra Kurla Complex, Pan : Aihpp2373C Bandra (East), Mumbai-400051. (Appellant) (Respondent) Assessee By : Shri Mihir Naniwadekar (Virtually Present) Shri Ruturaj Gurjar Revenue By : Shri Krishna Kumar, J.Cit Date Of Hearing : 05-06-2025 Date Of Pronouncement : 30-06-2025

For Appellant: Shri Mihir NaniwadekarFor Respondent: Shri Krishna Kumar, J.CIT

Section 133(6)Section 143(3)Section 144C(13)Section 270ASection 69A

pronounced in the open court on 30-06-2025 [SANDEEP SINGH KARHAIL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 30-06-2025 TNMM Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

Edwards Lifesciences (India) Pvt Ltd, Mumbai vs. ACIT-2(1)(1), Mumbai

In the result, the appeal by the assessee is partly allowed

ITA 6188/MUM/2024[2021-22]Status: DisposedITAT Mumbai30 Jun 2025AY 2021-22

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailedwards Lifesciences (India) Pvt. Ltd., 4Th Floor Commerz – Ii, International Business Park Oberoi Garden City, Goregaon (East), Off Western Express Highway Goregaon (East), ............... Appellant Mumbai - 400063 Pan : Aaacb4203F V/S Assistant Commissioner Of Income Tax, Circle-2(1)(1), ……………… Respondent Kautilya Bhawan, Bkc, Mumbai - 400012 Assessee By : Ms. Chandni Shah Ms. Riddhi Maru Ms. Kinjal Patel Revenue By : Shri Bhagirath Ramawat, Sr.Dr

For Appellant: Ms. Chandni ShahFor Respondent: Shri Bhagirath Ramawat, Sr.DR

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 92B

used No. 1. Purchase of Traded Goods 57,34,48,498 Transactional Net Margin 2. Aid from fellow subsidiaries 39,17,89,834 Method (TNMM) 3. Purchase return of traded goods 2,58,03,811 4. Purchase of fixed assets 1,20,000 5. Reimbursement of expenses

Bhagirathi Enterprise, Vile Parle West Mumbai vs. Income Tax Officer Ward 34(1)(1), Bandra East Mumbai

In the result, the appeal filed by the assessee for the AY

ITA 3130/MUM/2025[2023-24]Status: DisposedITAT Mumbai27 Jun 2025AY 2023-24

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopal

For Appellant: Shri Anant N. Pai, CAFor Respondent: Shri Leyaqat Ali Aafaqui

Section 143Section 143(1)Section 154Section 167BSection 2

pronounced in the open court on 27-06-2025 [MS. KAVITHA RAJAGOPAL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 27-06-2025 TNMM Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst

Bhagirathi Enterprise, Vile Parle West Mumbai vs. Income Tax Officer, Ward 34(1)(1), Mumbai Bandra East

In the result, the appeal filed by the assessee for the AY

ITA 3129/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopal

For Appellant: Shri Anant N. Pai, CAFor Respondent: Shri Leyaqat Ali Aafaqui

Section 143Section 143(1)Section 154Section 167BSection 2

Bhagirathi Enterprise, Vile Parle West Mumbai vs. ITO Ward 34(1)(1), Bandra East Mumbai

ITA 3128/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 Jun 2025AY 2021-22

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopal

For Appellant: Shri Anant N. Pai, CAFor Respondent: Shri Leyaqat Ali Aafaqui

Section 143Section 143(1)Section 154Section 167BSection 2

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “B” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND MS. KAVITHA